`Case 1:15—cv—OO311—RGA Document 108 Filed 03/25/16 Page 1 of 3 Page|D #: 3183
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`ACCELERATION BAY LLC,
`
`Plaintiff,
`
`v.
`
`ACTIVISION BLIZZARD, INC.,
`
`Defendant.
`
`ACCELERATION BAY LLC,
`
`Plaintiff,
`
`V.
`
`ELECTRONIC ARTS INC.,
`
`Defendant.
`
`ACCELERATION BAY LLC,
`
`Plaintiff,
`
`V.
`
`TAKE~TWO INTERACTIVE SOFTWARE,
`INC., ROCKSTAR GAMES, INC. and
`2K SPORTS, INC.,
`
`Defendants.
`
`
`
`
`
`\/\./\/\/\./\/\/\/xzxyyz\.z\./\/\/\/\/\/\.x\/\/\_/g/\./\./\/\/\_/\/
`
`CA. No. 15-228 (RGA)
`
`PUBLIC VERSION
`1
`
`CA. No. 15~282 (RGA)
`
`C.A. No. 15-311 (RGA)
`
`DECLARATION OF NATASHA RADOVSKY IN SUPPORT OF
`ACCELERATION BAY’S OPPOSITION TO DEFENDANTS’ MOTION TO DISMISS
`
`Public Version Dated: March 25, 2016
`
`
`
`Case 1:15-cv-00311-RGA Document 108 Filed 03/25/16 Page 2 of 3 PageID #: 3184
`Case 1:15—cv—OO311—RGA Document 108 Filed 03/25/16 Page 2 of 3 Page|D #: 3184
`
`1, Natasha Radovsky do declare and state as follows:
`
`1.
`
`I have personal knowledge of the facts stated herein and can testify competently
`
`to those facts.
`
`I make this declaration in support of Plaintiff Acceleration Bay LLC’s
`
`(“Acceleration Bay”) Opposition to Defendants’ Motion to Dismiss.
`
`2.
`
`Director, Global Patent and Technology Licensing, Boeing Intellectual Property
`
`Licensing Company. Responsible for leading the team that is in charge of rnonetization on
`
`Boeing’s ll’ assets. Specifically: oversee [P deal~tearn negotiations,
`
`technology and patent
`
`monetization strategies; patent and technology licensing; patent
`
`transactions (acquisitions /
`
`divestitures);
`
`contract negotiations;
`
`structuring patent
`
`and technology sale
`
`/
`
`licensing
`
`agreements;
`
`building
`
`strategic
`
`partnerships;
`
`business
`
`development;
`
`complex
`
`project
`
`management; IP deal structure and negotiations; market research and company financial analysis
`
`related to supporting patent and technology portfolio licensing campaign.
`
`3.
`
`I was personally involved with the negotiations between Acceleration Bay and
`
`Boeing over the December 10, 2014 Patent Purchase Agreement (the “Purchase Agreement”).
`
`I
`
`am also personally familiar with Boeing’s commercial activities, including its customers and the
`
`products and services that it provides.
`
`4.
`
`
`
`
`
`Case 1:15-cv-00311-RGA Document 108 Filed 03/25/16 Page 3 of 3 PageID #: 3185
`Case 1:15—cv—OO311—RGA Document 108 Filed 03/25/16 Page 3 of 3 Page|D #: 3185
`
`
`
`7.
`
`Boeing is among the largest global aircraft manufacturers and defense contractors
`
`in the world and designs, manufactures, and sells a variety of products, including airplanes, space
`
`' rockets, satellites and very sophisticated training simulations, as well as related services,
`
`including training. Boeing does not design or manufacture mass—Inarket entertainment video
`
`games.
`
`8.
`
`Boeing sells and leases training simulations, and provides training services using
`
`simulations. Boeing’s simulations are very expensive and sophisticated physical devices and
`
`software used to train pilots, astronauts and military personnel. Boeing’s simulations replicate
`
`actual conditions in an airplane cockpit or spacecraft for training purposes, and are also used to
`
`develop and test real~world aircraft and aerospace products, such as validating the performance
`
`of missile defense systems.
`
`I declare under penalty of perjury under the laws of the United States that the foregoing is
`
`true and correct. Executed on March 15”‘, 2016, in Huntington Beach, California.
`
`//
`,
`»,~’. /32 .[” /5//\*~*““"M
`Natasha Ra<{ovsky
`
`fl

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